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Fair Lending/Responsible Banking

Fair lending principles are embraced by CBA members. Regulatory enforcement, however, is an increasingly complex area of compliance, and has become even more challenging with the intense search at the state and federal levels for 'predatory lending' practices. To encourage self-evaluation, CBA helped establish a privilege for self-testing for fair lending compliance. CBA also is responding to new fair lending guidelines and protecting banks from unnecessary and burdensome small business data collection.

On Wednesday, May 25, 2016, the FDIC held a meeting of its Advisory Committee on Economic Inclusion to discuss ways mobile financial services (MFS) can be used to bring underserved consumers into the banking industry. In a report released the same day, FDIC researchers offered “seven core financial services needs” for underserved consumers: control over finances, access to money, convenience,...

Insight from Legal Experts and an Operations Veteran. The benefit of leveraging outsourced vendors to manage consumer contacts continues to be offset by the risk of being directly liable, or vicariously liable, for the outsourced vendors' actions. In an attempt to reduce liability, many creditors are incurring rapidly rising audit resource costs as they search for ways to exert control and gain...

On Tuesday, May 11, 2016, the U.S. Treasury Department published a white paper addressing the emerging marketplace lending sector of finance. Entitled: “Opportunities and Challenges in Online Marketplace Lending,” the document follows a Request for Information (RFI) issued in late 2015. Treasury described the document as a process to better understand the potential opportunities and risks...

Marketplace lenders need to be more transparent about their business practices and should be subject to additional oversight from federal regulators, according to a U.S. Treasury study released just as the industry grapples with market turmoil and a scandal facing one of the biggest lenders. Online lenders need to develop a public database for tracking data on their loans, and companies that lend...

Marketplace lenders need to be more transparent about their business practices and some should be subject to additional oversight from U.S. regulators, according to a Treasury Department study released as the industry grapples with market turmoil and a scandal involving one of its leading firms . Companies in the burgeoning industry need to develop a public database for tracking data on their...

Marketplace lenders need to be some-more pure about their business practices and some should be theme to additional slip from U.S. regulators, according to a Treasury Department investigate expelled as a courtesy grapples with marketplace misunderstanding and a liaison involving one of a leading firms . Companies in a burgeoning courtesy need to rise a open database for tracking information on...

Marketplace lenders need to be more transparent about their business practices and should be subject to additional oversight from federal regulators, according to a U.S. Treasury study released just as the industry grapples with market turmoil and a scandal facing one of the biggest lenders. Online lenders need to develop a public database for tracking data on their loans, and companies that lend...

Last week, the CFPB released its fourth Fair Lending Report outlinging the agency’s fair lending activity in 2015. A few notable items include: Regarding indirect auto, CFPB Director Director Cordray “urge[d] indirect auto lenders to carefully consider the terms of these orders as they evaluate compliance in their own lending programs.” Last year, the Office of Fair Lending and Equal Opportunity...

The consumer reporting industry has changed significantly over the last several years for furnishers large and small. The CFPB has continued to focus enforcement efforts on this space and has indicated that consumer reporting will remain one of their top priority areas.